This article will introduce you to elements of proactive safety by design approach at a general level.
Make a plan for proactive safety by design
In the development of your medical device, it is highly recommended that you identify the relevant requirements of the safety standards early during the design phase and then decide how the design is going to meet these. To ensure this, you should make a plan for proactive safety by design.
This plan can be an integral part of your design and development plan. Even better, make a separate plan referenced from the design and development plan, as demonstrated in the image below.
This plan should identify who is going to do what and when they are going to do it. It should also tell you how much activity is relevant, justified or practicable to assign to proactive safety by design.
How to meet the general requirements
Below are the four general requirements to address in the risk management file. These must all be met effectively, by ensuring that they are addressed in your final risk management file for your medical device.
The aim of safety engineering is to design a safe product while ensuring compliance with the standards. Adding hundreds of lines to your risk analysis matrix is not the way to achieve this; it would rarely meet the objectives and is likely to cause a lot of confusion.
Let’s focus on the column to the left labelled ‘Complete?’ in the table above. In order to identify if the requirements of the standards address all hazards associated with your device, you must consider two questions:
- Which hazards are associated with your device?
- Which of the requirements of the standards apply?
When you have done your analysis and answered these questions, you can perform a gap analysis, to identify any relevant hazards that are not fully covered by the standards.
Once the gap analysis is complete, you can go on to defining these additional requirements. This includes evaluation methods and acceptance criteria, allowing you to conclude that the risk is reduced to an acceptable level.
Combining the results of these analyses will give you a full list of the safety-related requirements applicable to your device. Some requirements will be defined by the standard, while others may be defined and justified by you.
The image below demonstrates this process, step by step.
You have now reached an important checkpoint and an appropriate stage in which to do a design review to ensure that you have carried out planned activities and that the results of the activities are relevant, correct, complete and consistent.
It is also a good idea to ensure that both activities and documentation are included in the risk management file and integrated into your risk analysis. If not, you may want to revise the plan or repeat relevant activities.
All of the recognised characteristics related to safety and hazards identified during the activities should be included in your risk analysis. Identify a hazard for each identified relevant requirement, whether it is identified by you or the standard.
In your risk analysis matrix, you then continue to complete risk analysis by defining foreseeable sequences of events and their resulting hazardous situations followed by risk estimation. The gap analysis should also be documented and included in your risk management file.
The safety requirements identified as relevant to your medical device should be fed into the risk control process. This is a process by which you identify risk control measures that are appropriate for reducing the risks to an acceptable level. Typically, this translates into a means of protection in IEC 60601.
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Claus Rømer Andersen
He is recognized as having a pragmatic and solution oriented approach to helping development teams focus on relevant issues throughout the entire product life-cycle.